On May 12, the U.S. Court of Appeals for the Second Circuit vacated the sentence of defendant Chase Dralle in U.S. v. Dralle.(1) Dralle pled guilty to one count of illegal receipt of a trafficked firearm in violation of Title 18 of the U.S. Code, Sections 933(a)(2) and (b).
The Second Circuit's decision has broad implications about the limitations of a district court's consideration of the conduct of others — whether co-conspirators or not — when sentencing the defendant without establishing a connection between someone else's conduct and the Section 3553(a) sentencing factors.(2)
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